Commonwealth v. Lyles, 626 Pa. 343

At 4:30 p.m., two uniformed officers in a marked car approached appellant Lyles and another male sitting on the steps of a vacant building in a high-burglary area and asked why they were there.
Lyles said his grandmother lived nearby; an officer then requested Lyles’s identification, which Lyles handed over voluntarily.
While the officer wrote the ID information, Lyles repeatedly put his right hand in his right pocket and turned away; the officer told him to stop and eventually performed a frisk. A plastic bag with crack cocaine fell out when the officer removed Lyles’s hand; marijuana was later found during search incident to arrest.
The trial court granted suppression, finding the officer’s request for identification elevated the encounter to an investigative detention unsupported by reasonable suspicion.
The Superior Court (majority) reversed, relying on Commonwealth v. Au and an objective totality-of-the-circumstances analysis; this Court affirmed the Superior Court, concluding the ID request alone did not constitute a seizure given the circumstances.
The dissent would have treated the record (viewed in the light most favorable to appellant) as supporting a seizure because the officer testified he had “stopped” Lyles, took possession of the ID, and believed Lyles was not free to leave.

Issue	Lyles' Argument	Commonwealth's Argument	Held
Whether an officer’s request for identification during a public encounter transforms a mere encounter into an investigative detention	Request for ID (and officer writing it down) signaled an intent to investigate and left Lyles no realistic option to leave	A request for ID does not, by itself, restrain liberty; Lyles could have declined or asked for his ID back; recording info is not coercive	Requesting ID, standing alone, does not convert an encounter into a seizure; totality of circumstances here show no detention before furtive movements began
Whether an officer briefly writing down ID information constitutes a coercive show of authority that restrains movement	Recording the information is a show of authority and indicia of detention	Jotting minimal info is reasonable, noncoercive, and does not impair freedom of movement	Writing down ID briefly did not objectively restrain Lyles’ liberty in these facts
Whether the officer’s subjective belief that Lyles was not free to leave is relevant to the seizure inquiry	Officer’s stated belief corroborates that a reasonable person would not feel free to leave	Subjective beliefs are immaterial; inquiry is objective under the totality of the circumstances	Officer’s subjective belief is irrelevant; seizure analysis is objective and based on conduct and setting

Commonwealth v. Au, 42 A.3d 1002 (Pa. 2012) (request for identification alone does not transform a mere encounter into an investigative detention)
Hiibel v. Sixth Judicial Dist. Court of Nevada, 542 U.S. 177 (2004) (officers may request identification without automatically implicating the Fourth Amendment)
Florida v. Bostick, 501 U.S. 429 (1991) (approach and request to question/ask for ID not necessarily a seizure absent coercive conduct)
Commonwealth v. Smith, 836 A.2d 5 (Pa. 2003) (discussing encounter/detention/arrest categories under state and federal constitutions)
Commonwealth v. Strickler, 757 A.2d 884 (Pa. 2000) (totality-of-the-circumstances and objective reasonable-person test for seizures)
Terry v. Ohio, 392 U.S. 1 (1968) (framework for investigative stops and the reasonable-suspicion standard)
Michigan v. Chesternut, 486 U.S. 567 (1988) (context matters in whether reasonable person would feel free to terminate an encounter)
Commonwealth v. Jones, 988 A.2d 649 (Pa. 2010) (review standard: factual findings of suppression court are binding if supported; seizure question is reviewed de novo)
In re D.M., 781 A.2d 1161 (Pa. 2001) (noting an individual retains the right to ignore police and go about his business)